Your CCPA Rights

The California Consumer Privacy Act as amended by the California Privacy Rights Act (the “CCPA”) provides certain verified California residents the following rights. For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Information Access Rights

As a California resident you have the right to request that we disclose certain information upon request about our information collection and disclosure practices. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a 12 month period. Once we receive and confirm your verifiable request, we will disclose to you:

Information Deletion Rights

California residents have the right to request that we delete any of your personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. You may make deletion requests at any time. Please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations.

Information Correction Rights

California residents have the right to request that we correct information that we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account. You can make information correction requests at any time.

Opt-Out Rights

Please note that we do not sell your personal information.

We do not share your personal information with third parties for cross-context or behavioral advertising purposes.

We only process Sensitive Personal Information for the purpose for which we originally collected it or as permitted by the CCPA.

Exercising your CCPA Rights

Access, Correction and Deletion: In order to make a request for access, correction and deletion rights California residents may contact us by calling us toll-free at 866-575-8310 or by visiting our CCPA request page here [link], and providing the information requested along with the right you choose to exercise. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. Any disclosures we provide will only cover the 12-month period preceding receipt of your request, but you may request that expand the 12-month period to cover information collected since January 1, 2022, and we will honor that expanded request unless doing so would involve a disproportionate effort. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

Opt-Out Rights:

We do not sell your personal information for monetary or other valuable consideration. We do not share your personal information with third parties for cross-context behavioral marketing purposes. We do not process of disclose your Sensitive Personal Information for purposes beyond those for which it was originally collected.

Using an Authorized Agent

You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorize the person to make the request on your behalf, (4) you verify your own identity directly with us and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

Non-Discrimination

We will not discriminate against you as a result of your exercise of any of these rights.

Information Collected, Sources, and Business Purpose for Collection

During the past 12 months NOF CORPORATION collected the following categories of information about California residents. Not all information is collected about all individuals. Information is collected directly from the individual, from third parties such as staffing partners or references, or by us for security or employee/vendor oversight purposes.

• • Identifiers (such as name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver's license number, passport number, unique personal identifier, IP address)
• • Protected Information (name with financial account, medical, health, and health insurance information, user name and password)
• • Protected anti-discrimination classification information (race, gender, ethnicity, religion)
• • Commercial information (transaction history, products/services purchased, obtained or considered, product preference)
• • Electronic network activity (browsing or search history, website interactions, advertisement interactions)
• • Audio, video or similar information (customer service calls, security monitoring)
• • Biometrics
• • Geolocation
• • Professional, educational or employment related information
• • Sensitive Personal Information (social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life or sexual orientation)
• • Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)

Disclosure of Personal Information

During the past 12 months NOF CORPORATION disclosed the following categories of information about California residents for a business purpose to the following categories of third parties. Business purposes are following:

1. Performing services for you:

• • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
• • To assist you in completing a transaction or order;
• • To allow tracking of shipments;
• • To prepare and process invoices;
• • To respond to queries or requests and to provide services and support;
• • To provide aftersales customer relationship management;
• • To create and manage our customer accounts;
• • To notify you about changes to our services and products;
• • To administer any promotion, contest, survey, or competition;
• • To provide you information regarding our products and services,
• • To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.



2. Advertising customization:

• • For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.



3. Auditing relating to transactions, internal research and development:

• • To provide for internal business administration and operations, including troubleshooting, our website (www.nof.co.jp) (“Site”) customization, enhancement or development, testing, research, administration and operation of our Sites and data analytics;
• • To create products or services that may meet your needs;
• • To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.



4. Security detection, protection and enforcement; functionality debugging, error repair:

• • As part of our efforts to keep our Sites safe and secure;
• • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Sites, for example, by requesting verification information in order to reset your account password (if applicable);
• • To ensure the physical security of our premises through the monitoring of surveillance images;
• • To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.



5. Quality control:

• • To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures.
• • To develop and improve our products and services, for example, by reviewing visits to the Sites and various subpages, demand for specific products and services and user comments.

We did not sell personal information. We did not share personal information for cross-context behavioral marketing purposes.

• • Identifiers – shared with service providers such as payment processors, employee benefits service providers, shipping partners, mail houses, marketing partners, legal and accounting providers, affiliated companies; may be shared with government regulators or law enforcement on legal request
• • Protected information – shared with payment processors, employee benefits service providers.
• • Commercial information – shared with affiliated companies for fulfillment purposes, service providers such as shipping partners, payment processors, mail houses, legal and accounting providers.
• • Electronic network activity – shared with webhosting provider
• • Professional, education or employment related information – shared with employee benefits providers and staffing provider, may be shared with government regulators or law enforcement on legal request
• • Sensitive Personal Information – employee/applicant/vendor sensitive personal information may be shared with benefits providers, staffing providers, legal and accounting providers, government regulators or law enforcement on legal request for legal compliance.

Sharing Personal Information for Cross-Context Behavioral Marketing

We do not share personal information for cross-context behavioral marketing purposes.

Retention of Personal Information.

We will store personal information in a form which permits us to identify consumers, for as long as necessary for the purpose for which the personal information is processed. We may retain and use such personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information consumers provide in connection with requests made under the CCPA for a period of five years.